Shri Prakash Javadekar
Union Minister
Union Ministry of Environment, Forests & Climate Change
Government of India
New Delhi
Date: September 16, 2014
Subject-
Objectionable approval to rejected Integrated Common Hazardous Waste
Treatment, Storage, Disposal and Recycling Facility by M/s Ramky Enviro
Engineers Ltd at Koilwar-Babura Road Bhojpur, Bihar
Sir,
With reference to my letter to Expert Appraisal Committee (EAC), Infrastructure and Miscellaneous Projects and CRZ
dated September 7, 2014 regarding an advertisement by Bihar State Pollution
Control Board (BSPCB) in The Times of India Patna edition dated
September 6, 2014 for the proposed public hearing on the Environment
Impact Assessment of the proposal for Integrated Common Hazardous Waste
treatment, storage, disposal and recycling facility by M/s Ramky Enviro
Engineers Ltd at Koilwar-Babura Road Bhojpur, Bihar, I wish to draw your attention towards the manifest inconsistency of EAC.
I wish to submit that
the approval for TOR for EIA and public hearing for the project in
question is contrary to EAC’s own recommendations besides all existing
environmental norms in the rule book including Hazardous Wastes
(Management, Handling and Trans-boundary movement)) Rules, 2008 and
Bio-Medical Waste (Management and Handling) Rules, 1998. The proposed
facility is in an ecologically sensitive zone. The hazardous
waste-cum-biomedical waste facility admittedly gives birth to risks of
all cancers and specifically of stomach, colorectal, liver and lung
cancer that increases with closer proximity to incinerators. The notice for public hearing is attached.
I
submit that the attached Minutes of the 118th Meeting of the EAC held
on 8th-9th November, 2012 reveals that the EAC concluded that M/s Ramky
Enviro Engineers Ltd the project “Proponent has not justified selection
of the site and also there is a habitation at about 200 m from the site
which is not advisable for this type of Hazardous waste handling and
incineration activity.”
I submit that the proposed
Integrated Common Hazardous Waste treatment, storage, disposal and
recycling facility is being sited exactly adjacent to Sone river in the
vicinity of residential areas of the village in the proximity of
Koilwar-Babura Road, Bhojpur in area of 57.24 acres of agricultural land.
I
submit that the manner in which EAC at its 125th Meeting held on 10th
-12th June, 2013 has gone against its own wisdom to assign Terms of
Reference of the Environment Impact Assessment (EIA) for public hearing
is quite enigmatic. It is evident from the recommendations for Sampling
Locations specified for hazardous waste treatment, storage, disposal
facility (TSDF) that the ground water samples should be collected
at least up to a distance of 5 KM from the TSDF location. This in effect
is an admission that at least 5 KM zone of the proposed facility is an
ecologically sensitive and vulnerable zone. According to US
Environment Protection Agency (USEPA), toxic emissions like Dioxins
travel long distances in the atmosphere and is found on plants, in
water, soil, grazing animals and humans.
I submit that
the grounds on which EAC reached its inference at its 118th Meeting
remains quite valid and scientific based on deep understanding of far
reaching implications of incinerator facilities. It is quite manifest
that the project proponent has misled the EAC regarding facts about the
location of the proposed hazardous waste facility to ensure that EAC
reverses its considered verdict about the inappropriateness of the site
in question. The Terms of Reference no. (viii) provided to the project
proponent states “Examine the details
of monitoring of Dioxin and
Furan”. This reveals that the proposed facility will emit dioxins and
other harmful pollutants. Dioxin is the common name for 75 toxic
chemicals that are unwanted by-products of manufacturing and combustion
processes when chlorine and carbon-containing materials are combined. It
must be noted Bihar State Pollution Control Board (BSPCB) does not have
the required infrastructure to deal with such toxic chemical emissions
which has been so lethal that it was used as a chemical weapon by USA
against Vietnam under the Brand name Agent Orange whose after effects
continues to trouble both the war veterans of USA and Vietnam.
I
submit that Garbage and medical incinerators have been identified as
the largest sources of dioxins in the US Environmental Protection Agency
(USEPA)’s reassessment reports on dioxin in 1994/2004. Dioxin
particles
are stored in fatty tissue and will accumulate to create “buildup” when
low-level exposure is continual. The International Agency for Research
on Cancer (IARC) concluded that dioxin is a human carcinogen.
Non-Hodgkin_ s lymphoma and cancers of the liver, lung, stomach, soft
and connective tissue have been associated with dioxin.
Even
at very low exposure, at levels of parts per trillion, dioxin causes
immune system damage, hormone disruption, and reproductive and
development effects. Some newer emission control devices have been
effective
in decreasing recorded dioxin air emissions from incinerators, but
there is no safe level additional exposure to dioxins. This is because
the average daily dioxin intake for is already 200 times higher than
what the US EPA defines as a safe dose for adults. Those most at risk of
receiving the highest concentrations
are babies. Studies also
show elevated levels of dioxin in the blood of people living near
municipal solid waste incinerators when compared to the general
population. Residents in Indian cities are rightly alarmed at the prospect of these incinerator plants coming up in their city.
I
submit that in February 2014 the 27th report of the Parliamentary
Committee on Urban Development has recommended that incinerator plants
should be stopped in all residential areas across the country in its
report
to the Parliament. Incinerators cause serious environmental and health
problems to the people living not only near them but even to those who
live several kilometers away from the source like the proposed facility.
I
submit that the advertisement of the Bihar State Pollution Control
Board (BSPCB) reveals that the proposed hazardous waste facility will
also incinerate bio-medical waste which is governed under Bio-Medical
Waste (Management and Handling) Rules, 1998 which provides that
“Bio-medical waste shall be treated and disposed of in accordance with
Schedule I, and in compliance with the standards prescribed in Schedule
V.” Schedule I provides Categories of Bio-Medical Waste. Schedule V
provides Standards for Treatment and Disposal of Bio-Medical Wastes. It
is noteworthy that the Schedule –II of the Municipal Solid Wastes
(Management and Handling) Rules, 2000 lays down the compliance criteria
stating “Bio-medical wastes and industrial wastes shall not be mixed
with municipal solid wastes and such wastes shall follow the rules
separately specified for the purpose.” The proposal is in contravention
of this criteria.
I submit that the 15 July, 2013
judgment of the Hon’ble Delhi High Court is quite germane in this
regard. The Hon’ble High Court judgment refers to ‘The summary of
“Epidemiological Studies on Adverse
Health Effects Associated with
Incineration” would show that medical waste incinerators are a leading
source of dioxins and mercury in the environment and there is link
between incinerator emissions and adverse health impacts on incinerator
workers and residents living around the incinerators.’ (Source:http://www.delhicourts.nic.in/
Hon’ble
Court’s judgment reads: “Both older and more modern incinerators can
contribute to the contamination of local soil and vegetation with
dioxins and heavy metals. In several European countries, cow‟s milk from
farms located in the vicinity of incinerators has been found to contain
elevated levels of dioxin, in some cases above regulatory limits.
Increased levels of dioxins have been found in the tissues of residents
near to incinerators in the UK, Spain and Japan. At an incinerator in
Finland, mercury was increased in hair of residents living in the
vicinity. Children living near a modern incinerator in Spain were found
to have elevated levels of urinary thioethers, a biomarker of toxic
exposure. “ It notes that
“After 2 years of operation of
incinerator, dioxins levels were found increased by about 25% in both
groups living between 0.5 to 1.5 and 3.5 to 4.0 km away (201 people) of
people. In the repeat analysis, the increase was in the range of 10-15%”.
The
judgment records that “Mothers living close to incinerators and
crematoria from 1956 to 1993” showed “increased risk of lethal
congenital abnormalities, in particular, spinal bifida and heart
defects, near incinerators: increased risk of stillbirths and
anacephalus near crematoria”.
I submit that with regard
to “Residents from 7 to 64 years old living within 5 km of an
incinerator and the incinerator workers” the judgment observes, “Levels
of mercury in hair increased with closer proximity to the incinerator
during a 10 year period”.
I submit that the judgment of
the Hon’ble High Court found that “Residents living within 10 km of an
incinerator, refinery, and waste disposal site” showed “Significant
increase in laryngeal cancer in men
living with closer proximity
to the incinerator and other pollution sources”. It observed that the
“Residents living around an incinerator and other pollution sources”
showed “Significant increase in lung cancer related specifically to
theincinerator”. The “People living within 7.5 km of 72 incinerators”
displayed “Risks of all cancers and specifically of stomach, colorectal,
liver and lung cancer increased with closer proximity to incinerators”.
In
view of the above mentioned facts, the public hearing for the project
is scheduled for 16.10.2014 at 11 AM at Ambika Sharan Singh High School,
Jamalpur, Post- Naya Mohammadpur, District- Bhojpur must
be cancelled failing which there will be bitter massive resistance from the villagers due to imminent public health crisis.
In
view of these facts, I seek your urgent intervention to address the
issue of environmental and public health rights of the present and
future generations of residents of villages on the Babura-Koilwar road in Bhojpur, Bihar.
I will be happy to meet you to brief you and share relevant documents in this regard.
Thanking You
Yours faithfully
(Gopal Krishna)
ToxicsWatch Alliance (TWA)
Mb: 09818089660, 08227816731
Web: www.toxicswatch.org
Cc
Shri Jitan Ram Manjhi, Chief Minister, Government of Bihar, Patna
Shri Raj Kumar Singh, Member of Parliament, Arrah
Shri Ashok Lavasa, Secretary, Union Ministry of Environment, Forests & Climate Change
Shri Anjani Kumar Singh, Chief Secretary, Government of Bihar
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